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BOSEKER v. COMMISSIONER

Docket No. 27643-82.

52 T.C.M. 70 (1986)

T.C. Memo. 1986-353

Edward H. Boseker and Yvonne J. Boseker v. Commissioner.

United States Tax Court.

Filed August 6, 1986.

Attorney(s) appearing for the Case

Howard M. Larsen, 1901 N. Broadway, Santa Ana, Calif., for the petitioners. Patrick E. McGinnis, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Year                             Deficiency

  1978 .............................. $83,025
  1979 ..............................   7,993
  1980 ..............................   7,197

After concessions, the issues for decision are whether petitioners are subject to the limitations...

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